Your cite is quoting the American Savings Promotion Act. It's intent is to allow an exception to the prohibitive laws and allow this raffle to bolster savings deposits. The ASP doesn't define much and there is no implementing regulation or guidance that I am aware of. The ASP requires deposit into a savings account, or a savings program. It doesn't say if a CD is acceptable, or an MMDA or a NOW, or if we use the 7-day notice rule to consider a savings, or what a savings program is.
Requiring the funds into a savings at your bank seems to hold with the spirit and intent, but there is no guidance. And if you required it be at your bank, how long can that requirement hold, or can the depositor withdraw and use the funds next week, next month, next year? The bank has no control once the funds are withdrawn and when the owner wants the funds, I would thing the most the bank could do would be to enforce it's contract, the 7 day notice period, which is ignored 99.999% of the time or 100% in most cases.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell